Policy Note - The Commission's approach to licensing of firms acting as Designated Administrators of Family PIFs (2025-10-15)

Summary

This GFSC policy note explains how firms already licensed under the Fiduciaries Law can obtain a new type of restricted licence under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 (POI Law) so they can act as Designated Administrator of a Family Private Investment Fund (Family PIF). It follows the May 2025 revision of the Private Investment Fund Rules and is aimed at opening up this specific role to fiduciary licensees who do not otherwise want a full POI licence.

• Who can apply: Firms currently licensed solely under the Fiduciaries Law as a primary licensee, whose primary business is fiduciary activity, and who want to act as Designated Administrator of one or more Family PIFs with no other POI-regulated activity.
• Nature of the licence: A 'limited' POI licence issued under Section 4 of the POI Law, subject to a condition restricting the firm to Restricted Activities undertaken solely in the Designated Administrator role for Family PIFs; the application must cover all Restricted Activities needed for that role, not just Administration.
• Fees: The application fee matches that for a full POI licence, but the annual fee for a limited licence is set at £1,000, a reduction reflecting the restricted scope of activity.
• Ongoing requirements: Limited licensees must comply with the POI Law and, where relevant, the Licensees (Conduct of Business) Rules 2021; the Commission is prepared to waive parts of the Licensees (Capital Adequacy) Rules 2021 and modify the Fiduciary Rules 2021, so that prudential requirements align with Fiduciary Rules financial resources/liquidity standards plus Cap Ad-consistent PII requirements.
• AML/CFT/CPF role: Under Handbook paragraph 4.58, each Family PIF must nominate a POI-licensed firm responsible for CDD on all investors; the limited POI licensee can fulfil this function, while other parties (e.g. custodian/bank) continue relying on Section 9.5 CDD provisions.
• How to apply: Eligible firms apply via the Commission's online Applications and Authorisations portal, explicitly indicating the application is for a 'limited' POI licence under this policy; early engagement with the Commission is encouraged before applying.

The policy does not prevent a fiduciary firm from instead seeking a full POI licence if it wants to undertake a broader range of investment activities. Existing mainstream fund administrators already licensed for this activity are unaffected and may continue acting as Family PIF administrators as before.

Key obligations

• A firm holding a 'limited' POI licence must comply with the POI Law, 2020.
• Limited licensees must comply with the Licensees (Conduct of Business) Rules, 2021 to the extent relevant to their restricted activities.
• Limited licensees remain subject to the Licensees (Capital Adequacy) Rules, 2021 except where waived, and must instead meet Fiduciary Rules 2021 financial resources and liquidity requirements plus Cap Ad-consistent professional indemnity insurance requirements.
• Each Family PIF must nominate a POI-licensed firm (which may be the limited licensee) to apply CDD measures to all investors in accordance with Handbook paragraph 4.58.
• An application for a limited POI licence must cover all Restricted Activities necessary to perform the Designated Administrator role for a Family PIF, not merely Administration.
• Applicant firms must demonstrate they meet the minimum criteria for licensing and have the relevant skills, expertise and resources for the Designated Administrator activities being applied for.
• Fiduciary firms obtaining a limited POI licence must ensure their policies, procedures and controls cover the relevant investment-related regulatory requirements applicable to their operations, in addition to continuing to meet their existing Fiduciary licence requirements.
• Applications must be made using the Commission's online Applications and Authorisations portal, clearly indicating the application is for a 'limited' POI licence under this policy.

Applies to

primary fiduciary licensees (Fiduciaries Law), Designated Administrators, POI licensees, Family Private Investment Funds